Proposal
1. To amend the Misuse of Drugs Regulations 2001 to allow the independent prescribing of any Controlled Drugs from Schedules 2,3,4 and 5 of the 2001 Regulations by Nurse Independent Prescribers and Pharmacist Independent Prescribers. (Para. 18)
The NPA fully support this proposal. Independent Pharmacist Prescribers currently can prescribe any drug for any clinical condition, except Controlled Drugs. Allowing them to prescribe any Controlled Drug for any clinical condition will improve patient care and allow professionals to prescribe fully within their area of competence. Supplementary Pharmacist and Nurse Prescribers have been permitted to prescribe Controlled Drugs since March 2005. This has shown non-medical prescribing of Controlled Drugs does not compromise patient safety. Pharmacists are healthcare professionals with training which gives them more expertise in medicines than any other healthcare professional. Removing the restriction on what they can prescribe will allow them to use this knowledge. For example, an Independent Prescriber may have an interest in pain management and allowing them to prescribe Controlled Drugs will enable them to run a complete pain clinic and reduce the need for referral which may be time consuming and inconvenient for the patient.
We agree that Independent Prescribers should only prescribe within their area of competence, after completing appropriate training. Appropriate training for pharmacists is already in place. In addition, pharmacists must participate in Continuing Professional Development, ensuring they keep up to date with their area of practice. We also agree prescribing and dispensing of any drug (but especially Controlled Drugs) should not be carried out by the same person.
Comments on the alternative options A-D as set out in the consultation paper:
Option A (para. 21)
The NPA do not believe that doing nothing would be the best solution for patients. Healthcare professionals with appropriate training should be able to prescribe a full range of medicines for the condition they are treating.
Option B (para. 23)
Allowing pharmacists to prescribe from a limited list of Controlled Drugs in line with nurses will continue the current confusion that exists for both prescribing nurses and community pharmacists. Community pharmacists currently spend a large amount of time checking whether a prescribed item is on the list of Controlled Drugs allowed. Having no restrictions on this list would free up pharmacists time and ensure they do not inadvertently dispense items that independent prescribers are not permitted to prescribe.
Option C (para. 25)
Giving freedom to prescribe any Schedule 4 or 5 Controlled Drug, but restricting which Schedules 2 and 3 Controlled Drugs can be prescribed, will again lead to confusion – for both the prescriber and dispensing pharmacist. Prescribers may not be aware of which Schedules contain which drugs, and again dispensing pharmacists will spend time checking if an item is allowed.
Option D (para. 26)
As in Option C, the NPA believe confusion would arise if Schedules 4 and 5 were allowed to be prescribed in their entirety while schedules 2 and 3 were restricted. Removing the restriction on medical conditions would not remove this confusion.
2. We also welcome views on whether the Misuse of Drugs (Supply to Addicts) Regulations 1997 should be amended to allow Nurse and Pharmacist Supplementary Prescribers or Nurse and Pharmacist Independent Prescribers to prescribe diamorphine, cocaine or dipipanone for addicts for the management of addiction under Home Office licence. (Para. 30)
The NPA believe Nurse and Pharmacist Supplementary and Independent prescribers should be able to prescribe from a full range of Controlled Drugs, including diamorphine, cocaine and dipipanone. Licences to prescribe these are normally only issued to specialist prescribers, or those prescribing under the guidance of a specialist prescriber. Nurse and Pharmacist Prescribers, with appropriate training, could work under the guidance of a specialist prescriber. Nurse and Pharmacist specialists already work in areas of psychiatry and addiction. Additional training for those already in these roles should not be a significant burden.
In conclusion, the NPA supports non-medical prescribers being able to prescribe a full range of Controlled Drugs for a full range of conditions, within their area of competence.
